The Decision Of 1946: The Legislative Reorganization Act .
The Decision of 1946: TheLegislative ReorganizationAct and the AdministrativeProcedure ActJoseph PostellCSAS Working Paper 20-21First Branch, Second Thoughts — What Is Congress’s Proper Role in theAdministrative State?
The Decision of 1946:The Legislative Reorganization Act and the Administrative Procedure ActJoseph Postell*In the summer of 1946, Congress enacted two laws that served as the foundation of themodern administrative state. One of them is well-known to scholars of administrative law; theother, to scholars of Congress. The first, the Administrative Procedure Act (APA), establishedprocedural requirements for administrative rulemaking and adjudication and outlined the scopeof judicial review of administrative decisions. The second, the Legislative Reorganization Act(LRA), restructured Congress’s committee system and dedicated resources to enable Congress toengage in “continuous watchfulness” over the bureaucracy. Their enactment less than two yearsafter the death of President Franklin Roosevelt and the conclusion of World War II marked theend of a period of contestation between Congress and the President over both the legitimacy andthe control of the modern administrative state.Given the centrality of the APA to the functioning of the modern administrative state, andthe importance of the LRA to how the modern Congress functions, it is surprising that these twolaws are rarely considered in conjunction. The timing of their enactment suggests that membersof Congress were not considering them as isolated or separate reforms. There are two exceptionsto this neglect. David H. Rosenbloom’s Building a Legislative-Centered Public Administrationargues that “The Question in 1946” that animated both the APA and LRA was: “WhoseBureaucracy Is This, Anyway?”2 Congress answered that question, he concludes, by affirmingthat it was Congress’s bureaucracy: “Congress’s effort to redefine its constitutional position visà-vis federal administration in 1946 relied heavily on the idea that agencies should operate andbe treated as extensions of the legislature.”3 Congress, in other words, declared itself to be thesupervisor and controller of the administrative state. It accepted the delegation of many of itsformer responsibilities to administrative agencies, and focused on controlling agency power*Associate Professor of Politics, Hillsdale College. For helpful comments and encouragement, I am grateful toparticipants at the C. Boyden Gray Center for the Study of the Administrative State’s research roundtable. Thanksespecially to Jeremy Rabkin for valuable feedback on an earlier draft of this article. I also thank Joey Barretta forhelpful research assistance.2Rosenbloom, BUILDING A LEGISLATIVE-CENTERED PUBLIC ADMINISTRATION (2000), 14.3Rosenbloom, supra note 1, at 23.1
rather than limiting it.4 In addition, Joanna Grisinger has explained that both the APA and LRA“reflected Congress’s fundamental uneasiness that bureaucrats had become the primary makersof law and policy in the modern state.”5 The goal of the LRA, at least, Grisinger argues, was to“restor[e] Congress to its rightful place of primacy over the administrative state.”6The promise of Congress’s work in the summer of 1946, however, was largelyunfulfilled. Both the APA and the LRA have operated very differently in practice than they wereintended to operate in theory. Subsequent developments in Congress have altered and weakenedthe control over bureaucracy that Congress anticipated in the LRA. In addition, the APA hasfunctioned differently in practice than the members of Congress who enacted it intended. Thisarticle aims to describe the connection between these two important statutes as well as thesubsequent developments that altered the “Decision of 1946” in practice.The description and the argument of this article take place in five parts. Part I profiles the79th Congress that enacted both the APA and the LRA and briefly describes the timeline of bothlaws’ enactment in the Summer of 1946. Part II summarizes the arguments and debates aroundthe passage of the APA, emphasizing the assumption of many members that it was an initial firststep towards limiting the administrative state that had emerged over the previous decades. PartsIII and IV form the heart of the article. Part III thoroughly examines the hearings and debatesthat led to enactment of the LRA, focusing particularly on how members of Congress sought toposition the institution in relation to the administrative state it had just sanctioned in the APA.Part IV describes the failure of the LRA to live up to its promise, and how subsequentdevelopments in Congress thwarted the ultimate design of the law. It also describes in brief thestory, well-known to most administrative law scholars, of the disjunction between the APA asoriginally enacted and its contemporary application. This Part explains how the decisionCongress made in the summer of 1946 to accept but restrain the administrative state throughcongressional oversight failed to be achieved in the years following the decision.4Rosenbloom, Whose Bureaucracy is This, Anyway? Congress’ 1946 Answer, 34 PS: POL. SCI. AND POLITICS 773(2001), 774: “by 1946, the members [of Congress] accepted delegation as an unavoidable necessity.” See alsoRosenbloom, 1946: Framing a Lasting Congressional Response to the Administrative State, 50 Admin. L. Rev. 173(1998).5Joanna Grisinger, THE UNWIELDY AMERICAN STATE: ADMINISTRATIVE POLITICS SINCE THE NEW DEAL (2012),109.6Grisinger, supra note X, at 111.2
Finally, in Part V, the article explores the implications of the failure of the decision of1946 to take hold. The conclusions in Part V are offered in light of the fact that the summer of1946 marks a major settlement and reframing of the relationship between Congress and the NewDeal administrative state. The summer of 1946 represents a time when members of Congress,across the ideological spectrum, came to a settlement over the legitimacy of the New Dealagencies, and sought to constrain those agencies through administrative procedure and(primarily) legislative control. As the goal of expanding legislative control through areconstituted committee system governed by party leaders failed to materialize, the APA wassteadily reinterpreted to impose judicial controls on the administrative state in place of thecongressional controls that the LRA was supposed to create. One implication of the failure ofthe decision of 1946 to take hold, therefore, was the reinterpretation of the APA – a connectionthat has never been fully appreciated by legal scholars. This development has dramaticallyaffected how administrative law is taught and understood.Part I: The 79th Congress and the Summer of ’46As with most mid-century congresses, the Democratic Party enjoyed majority controlduring the 79th Congress, which began its first session on January 3, 1945 and adjourned itssecond session on August 2, 1946, the day that President Truman signed the LRA. At thebeginning of the 79th Congress Democrats held a 244-189-1-1 majority in the House and a 5738-1 majority in the Senate (Robert LaFollette, Jr. of Wisconsin was a member of theProgressive Party and an integral figure in the debates over the LRA).7 This majority wasrelatively stable leading up to the 1944 elections, but Democrats enjoyed a slightly largermajority than usual. Democrats picked up 20 seats in the House in 1944 and lost one seat in theSenate. Samuel Rayburn (D-TX), the longstanding Speaker of the House, was Speaker duringthe 79th Congress, and Alben Barkley (D-KY), a supporter of Roosevelt and the New Deal, wasthe Senate’s Majority Leader (and eventually Vice President during President Truman’s secondterm).7These numbers changed slightly during the 79th Congress due to vacancies in both the House and the Senate.Democratic majorities were diminished slightly in both chambers, but not significantly enough to alter the politicaldynamics. Two members of the House of Representatives came from third parties: Merlin Hull, Progressive fromWisconsin, and Vito Marcantonio, American Labor Party representative from New York.3
Democrats were punished by voters in the 1946 congressional elections, however, andRepublicans gained control of both houses, an unusual occurrence during this period. In the1946 elections Republicans gained 55 seats for a 246-188 majority in the House and won twelveSenate seats, receiving a 51-45 majority. Senator LaFollette was defeated by Joseph McCarthy.Richard Nixon won his first term in the House of Representatives. There is considerableevidence that members of both parties knew the Democratic majority may change hands in1946.8The Republican majority was short-lived. The party, which had not controlled eitherchamber since 1932, and lost control of Congress two years later as a result of the 1948elections. President Truman campaigned against the “Do Nothing Congress,” and Democratsretook both chambers.9 The coalition that enacted the APA and the LRA in the summer of 1946,in sum, was replaced by voters with a Republican majority in the elections in the fall. That newmajority was once again replaced in the 1948 elections, returning a Democratic majority to bothchambers.The Enactment of the APA and LRABoth the APA and the LRA were considered by special committees throughout 1945, anddebated and enacted in the summer of 1946. The APA, as discussed in the following section,was the product of several years of contestation between Congress and the president over theauthority, discretion, and control of administrative agencies.10 These battles produced severaldifferent reform proposals, one of which passed Congress but was successfully vetoed byRoosevelt, in the late 1930s: well before the APA emerged. The American Bar Association(ABA) sharply criticized the lack of legal process in administrative agencies, and laid the8Gary A. Donaldson writes, “as the 1946 congressional elections approached, the Republicans prepared for asignificant gain in their congressional power. As early as June, the Democratic National Committee (DNC) waswilling to admit privately that the Democrats might lose control of the House.” Donaldson, TRUMAN DEFEATSDEWEY (2014), at 5. One political cartoon from July 1946 depicted Barkley and Rayburn presenting theLegislative Reorganization Act to “John Q. Public,” but “Public” responds that “you ought to see the reorganizationplan we’re working on for next November.”9Truman’s slogan was a misnomer. The 80th Congress passed many important bills, such as the Taft-Hartley Actlimiting the authority of the National Labor Relations Board, the National Security Act of 1947 which restructuredthe nation’s security and intelligence agencies, the Federal Water Pollution Control Act, and the Foreign AssistanceAct, known colloquially as the Marshall Plan. In addition, the 80th Congress passed the 22nd Amendment, sending itto the states for ratification, and created the first Hoover Commission.10See George B. Shepherd, Fierce Compromise: the Administrative Procedure Act Emerges from New DealPolitics, 90 NORTHWESTERN L. REV. 1557 (1996).4
groundwork for fundamental reform. In Congress itself, hearings were held on the APA in thesummer of 1945, and the bill was brought before the Senate on March 12, 1946 for debate. TheSenate passed the APA on that date by unanimous consent with no dissent. From there, the APAwent to the House, where it was approved on May 24, again with no dissent. Some technicalamendments were adopted by the House and enacted by the Senate on May 27, and the APAbecame law with President Truman’s signature on June 11, 1946.The LRA came a few months later, but it was being considered at the same time. Itslegislative history, though shorter than the APA’s, followed a parallel path. A professionalorganization, the American Political Science Association, formed a committee in 1941 to studythe modernization of Congress. That committee issued a report several years later, right beforeCongress formed the Joint Committee on the Organization of Congress (JCOC) in February of1945. That committee, also known as the Monroney-LaFollette committee, held extensivehearings from March-June 1945 (just before the hearings were held on the APA). The JCOC’sreport was issued on March 1946, and the Senate debated the LRA on June 5-10 of 1946. TheSenate passed the measure on June 10, by a 49-16 vote, but the bill was delayed in the House, asSpeaker Rayburn stalled to avoid conflicts with powerful House committee chairs. On July 25,1946, the House debated the bill and approved various amendments, passing the LRA by a 22961 vote. The Senate approved the new bill on July 26 by voice vote, and Truman signed theLRA into law on August 2, 1946.The full details of the legislative history and debates for both measures are the subjectof the following sections, but this cursory view indicates that the two measures were under studyand consideration at the same time, and ultimately were signed into law within two months ofeach other. They were not passed hastily, and each was the product of months (even years) ofcareful study. Both were informed by professional organizations that issued reports onadministrative procedure and congressional modernization in the years leading up to theirenactment. Both were controversial and highly-visible laws. Although each was passed by awide majority – and in the case of the APA, by voice vote – leading members believed that theyhad overcome significant opposition in order to obtain passage. This was especially true of theLRA. Then-Representative Estes Kefauver (D-TN) and Jack Levin wrote a year after its passagethat its enactment “upset all predictions” and that it faced “a bitter uphill fight in both the Senate5
and House to shake Congress loose from two decades of inertia.”11 Given the conflictsurrounding both laws, and their visibility, it is reasonable to assume that members understoodhow the two measures would interact and would have one in mind when considering the other,and vice versa. The fuller history of the two measures generally supports these assumptions.Part II: The Administrative Procedure Act: A Pioneer EffortAs George Shepherd has explained, the APA was the product of a “fierce compromise”over the legitimacy of the administrative state that had emerged during the New Deal.12 Inparticular, lawyers and judges understood that they stood to lose much of their authority in thetransfer of political power from courts to administrative agencies. As Franklin Roosevelt put itin his veto message on the Walter-Logan Act, a measure predating but in some ways anticipatingthe APA, “a large part of the legal profession has never reconciled itself to the existence of theadministrative tribunal. Many of them prefer the stately ritual of the courts, in which lawyersplay all the speaking parts, to the simple procedure of administrative hearings which a client canunderstand and even participate in.”13 Roosevelt believed that the bar was the source ofmeasures to restrain the power of administrative agencies, and if the statements of the AmericanBar Association (ABA) at the end of the 1930s were any indication, he was correct in thisassessment.The ABA’s concerns over the rise of the administrative state emerged along with theNew Deal itself. In 1933 the ABA formed a special committee on administrative law, whichproposed placing the power of adjudication back into the independent judiciary rather thanadministrative agencies. Five years later, the ABA issued its infamous report denouncing the“administrative absolutism” of the New Deal.14 Eventually the ABA shifted from pressing forwholesale transfer of adjudication into independent courts, to advocating review boards in eachadministrative agency to review all decisions made by their personnel. Congress responded tothese calls by passing the Walter-Logan Act in 1939. Walter-Logan would have subjectedagencies to stronger judicial controls as well as more significant internal review procedures to11Estes Kefauver and Jack Levin, A TWENTIETH-CENTURY CONGRESS (1947), 220.Shepherd, supra note X.13Roosevelt, “Veto of a Bill Regulating Administrative Agencies,” December 8, 1940, available online via “TheAmerican Presidency Project,” at http://www.presidency.ucsb.edu/ws/index.php?pid 15914.14Report of the Special Committee on Administrative Law, 63 ANN. REP. A.B.A. 331 (1938), 346.126
protect individuals aggrieved by agency decisions. It also would have required trial-typehearings for rulemaking and adjudication. Franklin Roosevelt’s veto ensured that Walter-Loganwould not become law, but Congress continued to work towards passage of a compromise billthat could survive the president’s veto.The APA’s Original VisionThe debates on the APA shed light on its intended purpose. Generally speaking, in thewords of Sen. Patrick McCarran (R-NV), who led the floor debates on the bill, the goal of thelaw was to “cut down on the ‘cult of discretion’” that had emerged “in the last decade or so.”15This was particularly true of the scope of review section, which provided that reviewing courts“shall decide all relevant questions of law.”16 As Francis Walter (D-PA) (after whom WalterLogan was partially named) explained on the floor of the House, the APA “requires courts todetermine independently all relevant questions of law, including the interpretation ofconstitutional or statutory provisions.”17 Walter added the word “independently” in his summaryof this statutory provision, in line with several members’ comments on the floor of Congressrelating to this section. Generally, members agreed that the APA would establish judicial reviewof agencies’ statutory interpretations.18Other provisions similarly limited the discretion and authority of administrative agencies.While the APA did not go so far as to create a complete separation of functions between agencyprosecutors and adjudicators, it created an internal separation of functions that served as a middleground between the current law and recommendations for a stricter separation. Rep. Howard W.Smith (D-VA) expressed hope for “a more complete separation of the judicial and executivefunctions” in the APA, but Francis Walter noted that the “‘internal’ separation of functions”would still mark an improvement over the current law.1915Patrick McCarran, Improving ‘Administrative Justice’: Hearings and Evidence; Scope of Judicial Review, 32A.B.A. Journal 827 (1946), 893.165 U.S.C. §706(2)(A).17ADMINISTRATIVE PROCEDURE ACT: LEGISLATIVE HISTORY, 79TH CONGRESS, 1944-1946 (1946), 370.18See Aditya Bamzai, The Origins of Judicial Deference to Executive Interpretation, 126 Yale Law Journal 908(2017), at 988-990; Joseph Postell, Bureaucracy in America: The Administrative State’s Challenge to ConstitutionalGovernment (2017), at 240-242.19APA LEGISLATIVE HISTORY, supra note X, at 348, 362.7
The consensus that prevailed during the legislative debates over the APA, in sum,suggested that members of Congress intended it to serve as a constraint on the administrativestate. It was generally acknowledged to be the product of careful study and compromise, and itsprovisions for administrative procedure, agency structure, and scope of judicial review weredesigned to place limits on how agencies could function in the future. Some viewed it as a finalsettlement of the New Deal controversy over the administrative state, but others announced, asthe debates came to a conclusion, that the law marked the first step in a long process of limitingand constraining administrative authority. Rep. Earl Michener (R-MI) captured the sentiment ofthese reformers when he called the law “a pioneer effort” that “can be amplified ascircumstances warrant.”20 Rep. John Gwynne (R-IA) said, more forcefully, that the APA was “astart at least along the road that we must travel to regulate the many bureaus and tribunals thatare now operating in the executive branch of the Government.”21 Sen. McCarran wrote an articleafter the APA’s passage arguing that Congress still needed “to probe deeper into the generalproblem of regulatory government. We must do that, lest we become deluded into thinking thatwhat we have done, or are now doing, marks the end of the road to which there is, in truth, noend.”22 Perhaps the most colorful statement was from John Jennings Jr. (R-TN), who said thatthe APA was “a step in the right direction, but many more of the same tenor and effect need tobe taken by Congress .The chief indoor sport of the Federal bureaucrat is to evolve out of hisown consciousness, like a spider spins his web, countless confusing rules and regulations whichmay deprive a man of his property, his liberty, and bedevil the very life out of him.”23 Most ofthe members who suggested further reforms would be forthcoming were Republicans. SinceRepublicans had some reason to think they may be the majority party in the subsequentCongress, they were perhaps laying the groundwork for a second bill that would augment theconstrains the APA placed on administrative agencies.The most vocal supporters and contributors to the legislative debates surrounding theAPA, as indicated by these statements, were the critics of the administrative state. Supportersand moderates agreed with the provisions of the bill but were less emphatic about the need for20APA LEGISLATIVE HISTORY, supra note X, at 347.APA LEGISLATIVE HISTORY, supra note X, at 373.22Patrick McCarran, The Unwritten and Irrational Constitution of Regulatory Government in the United States, 24Notre Dame L. Rev. 62 (1948), 62.23APA LEGISLATIVE HISTORY, supra note X, at 392.218
future reforms. Sen. McCarran, for instance, spoke in grandiose terms about the significance ofthe APA and the nature of the problem it addressed. He famously called the APA “a bill ofrights for the hundreds of thousands of Americans whose affairs are controlled or regulated inone way or another by agencies of the Federal Government.”24 Yet he admitted that in manycases, such as regarding the admissibility of evidence, “we sought an intermediate ground whichwe thought would be protective of the rights of individuals, and at the same time would nothandicap the agencies.”25In short, the APA was most strenuously supported by critics of the administrative state,who were the most vocal in the legislative debates, and who clearly indicated their desire tofollow the APA with further and stricter reforms. But others supported the APA because itseffects were modest and would not disrupt the administrative state that had been establishedduring the New Deal. As one contemporary wrote colorfully in the Yale Law Journal, “[t]hebasic purpose of the APA was obviously the wish to bring about, somehow, a curb of theadministrative branch of our government .Its passage in part at least was due to the deepyearning of the traditional lawyer ‘for the comparatively simple life of yesteryear’ and his desireto put brakes on any new development in the law that disturbed his accustomed way of doingbusiness. The main protagonist of this yearning was the American Bar Association.”26Nevertheless, he insisted, while the APA “naturally curbs administrative agencies to a certaindegree,” those changes “do not come close to an effective curb of the administrative branch ofthe Government as such.”27 The APA received broad, unanimous support in Congress becausecritics of the administrative state saw it as a first step to be followed by more significant reformsand the supporters of the administrative state understood that it would not significantly changethe way it functioned.Part III: The Legislative Reorganization Act: Congress Asserts ItselfWhile the APA was, in part, the product of experts from the bar, the LRA was spurred byreform proposals that emerged from political scientists. As mentioned above, their professionalorganization, the American Political Science Association (APSA), formed a “Committee on24APA LEGISLATIVE HISTORY, supra note X, at 298.APA LEGISLATIVE HISTORY, supra note X, at 320.26Reginald Parker, The Administrative Procedure Act: A Study in Overestimation, 60 Yale L. J. 581 (1951), 583.27Parker, supra note X, at 587.259
Congress” in 1941 to produce articles and reports recommending a restructuring of Congress.Many of the APSA’s proposals would work their way into the LRA.The Political Scientists Weigh InPolitical scientists during the mid-20th Century regarded Congress as a hopelesslyoutdated institution. It was easy to come to this conclusion in light of two factors: the growingcomplexity and rapidity of governmental action, and the arcane rules and procedures that hadbuilt up in Congress over time. As Roger Davidson writes, “[w]ithin the political scienceprofession there was a generation of intellectuals trained in ‘scientific management’ wholooked with horror on what they regarded, no doubt rightly, as a messy, tradition-boundorganization.”28 APSA’s five-member “Committee on Congress” was formed in 1941 and waschaired by George Galloway, who had previously worked for the National RecoveryAdministration.29 Under Galloway’s leadership the APSA committee produced a report in 1945whose recommendations, unsurprisingly, “presaged those eventually made by the JointCommittee on the Organization of Congress” where Galloway would eventually serve as staffdirector.30The political scientists’ committee was more aggressive in its proposals than thecongressional committee that succeeded it, presumably because the members of the committeewere less concerned about the political ramifications of their proposals. For instance, the APSAcommittee addressed the problems associated with using seniority to determine committeechairs. This seniority principle, combined with the significant powers held by the committeechairs appointed under that principle, led to a system where the most senior (and moreconservative) members of the House controlled veto points that enabled them to obstructlegislation preferred by their junior colleagues. The APSA committee understood the politicalchallenge of unseating these chairs, but recommended alternatives such as imposing term limitsor age limits on chairs.31 While these solutions had little chance of making their way into the28Roger H. Davidson, The Advent of the Modern Congress: The Legislative Reorganization Act of 1946, 15 LEG.STUD. QUARTERLY 357 (1990), 362.29Daniel Stid, Two Pathways for Congressional Reform, in IS CONGRESS BROKEN? THE VIRTUES AND DEFECTS OFPARTISANSHIP AND GRIDLOCK (William F. Connelly, Jr., John Pitney Jr., and Gary Schmitt, ed., 2017), 12.30Davidson, supra note X, at 362-3.31THE REORGANIZATION OF CONGRESS: A REPORT OF THE COMMITTEE ON CONGRESS OF THE AMERICAN POLITICALSCIENCE ASSOCIATION (1945), 33-7, 80, quoted in Stid, supra note X, at 14.10
legislation, given the power that committee chairs had in both chambers, other proposalsessentially formed the basis of the congressional committee’s suggestions and the finallegislation itself. The APSA’s Committee on Congress was followed by the creation of acongressional committee that would share the same views and aims as the political scientists.The LaFollette-Monroney CommitteeThe Joint Committee on the Organization of Congress (JCOC) was chaired byRepresentative A.S. Mike Monroney (D-OK) and Senator Robert M. LaFollette, Jr. (ProgressiveWI). Monroney and LaFollette would go on to coauthor the LRA, and LaFollette led the floordebates over its passage in the Senate. The JCOC was a bipartisan group of twelve legislators(six Democrats, five Republicans, and LaFollette) and the reorganization proposal it devised wasreported unanimously.32 The Committee began its deliberations in spring of 1945, holding 39days of hearings and receiving testimony from over a hundred witnesses before issuing itsreport.33 Proposals to weaken the seniority principle were quickly dropped, and the Committeefocused instead on weakening the discretion of the committee chairs and increasing committeetransparency.The JCOC discussed whether and how to address the seniority system, but failed to agreeon any proposals. One problem, as already indicated, was political: the bill could not pass ifresisted by powerful committee barons. This was likely the critical factor. The problem wasalso substantive, however. All of the alternatives to the seniority principle – giving party leadersthe power to choose chairs, setting term limits, or allowing the majority party caucus to namechairs – posed their own difficulties.34 As Sen. LaFollette testified at the committee hearings,there was no “solution better than the disease.”35 In addition to avoiding the problem ofchanging the seniority principle, the JCOC was explicitly forbidden from making anyrecommendations that would alter the rules and procedures of either chamber of Congress.3632Eric Shickler, DISJOINTED PLURALISM: INSTITUTIONAL INNOVATION AND THE DEVELOPMENT OF THE U.S.CONGRESS (2001), 141. Though it was reported unanimously, Shickler notes that three Democrats dissented fromspecific measures in the proposal. Id.33Davidson, supra note X, at 363.34James L. Sundquist, THE DECLINE AND RESURGENCE OF CONGRESS (1981), 181.35Cited in Sundquist, supra note X, at 181.36Congressional Institute, “Joint Committees on the Organization of Congress: A Short History (2015), 4.(Available online at ief history reform committees.pdf.11
Aside from these critical omissions, however, most of the core features of the LRA wereanticipated in the JCOC report. First, the report advocated streamlining and reorganizingCongress’s committee system to match the structure of the federal bureaucracy that had emergedover the past decades. Second, it supported increased staff resources and expertise withinCongress so that it could compete with the vast staff and information capacities of the agencies.Third, it insisted upon the need for congressional committe
2 rather than limiting it.4 In addition, Joanna Grisinger has explained that both the APA and LRA “reflected Congress’s fundamental uneasiness that bureaucrats had become the primary makers of law and policy in the modern state.”5 The goal of the LRA, at least, Grisinger argues, was to “restor[e] Congress to its r
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